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McCabe v. New York State Employees' Retirement System

Citations: 221 A.D.2d 796; 633 N.Y.S.2d 432; 1995 N.Y. App. Div. LEXIS 11771

Court: Appellate Division of the Supreme Court of the State of New York; November 15, 1995; New York; State Appellate Court

Narrative Opinion Summary

A petition for review under CPLR article 78 was filed following the denial of accidental disability retirement benefits to a former Correction Officer with the Suffolk County Sheriff’s Department. The denial stemmed from an incident in March 1986 when the officer slipped and fell on a wet floor, which led to a light duty assignment. The respondent found that the officer was not permanently incapacitated from performing his duties as a result of the accident. The petitioner argued that this determination lacked substantial evidence. However, the court concluded that while there was evidence of the officer's disability from active duty assignments, there was no evidence indicating he was permanently incapacitated from light duty roles. Thus, the court upheld the respondent’s determination, confirming the denial of benefits and dismissing the petition without costs.

Legal Issues Addressed

Accidental Disability Retirement Benefits under CPLR Article 78

Application: The court upheld the denial of accidental disability retirement benefits to the petitioner, finding that the evidence did not support a claim of permanent incapacitation from all duties.

Reasoning: The respondent found that the officer was not permanently incapacitated from performing his duties as a result of the accident.

Judicial Review of Administrative Decisions

Application: The court reviewed the administrative decision under CPLR Article 78 and confirmed the denial of benefits, dismissing the petitioner's case without costs.

Reasoning: Thus, the court upheld the respondent’s determination, confirming the denial of benefits and dismissing the petition without costs.

Substantial Evidence in Administrative Determinations

Application: The court determined that the respondent's decision was supported by substantial evidence and therefore dismissed the petitioner's claim.

Reasoning: The petitioner argued that this determination lacked substantial evidence. However, the court concluded that while there was evidence of the officer's disability from active duty assignments, there was no evidence indicating he was permanently incapacitated from light duty roles.